PTAB

IPR2018-01240

Intel Corp v. Qualcomm Inc

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Apparatus for Generating Supply Voltages
  • Brief Description: The ’558 patent discloses techniques for efficiently generating a power supply for a power amplifier (PA) in wireless devices. The described apparatus uses a hybrid architecture combining a high-efficiency switcher with a high-bandwidth envelope amplifier, where a boost converter can selectively provide a higher voltage to the envelope amplifier to maintain performance when the primary battery voltage is low.

3. Grounds for Unpatentability

Ground 1: Obviousness of Claim 10 over Chu, Choi 2010, and Hanington

  • Prior Art Relied Upon: Chu (a 2008 IEEE journal article), Choi 2010 (a 2010 IEEE conference paper), and Hanington (a 1999 IEEE journal article).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Chu disclosed the core elements of claim 10: a hybrid supply generator for a PA combining a linear envelope amplifier and a switcher. Chu’s envelope amplifier was shown to include the specific internal components—an operational amplifier, a driver, a PMOS transistor, and an NMOS transistor—that the patent examiner previously found missing from the prior art of record. Petitioner asserted that while Chu powers its amplifier from a battery, Choi 2010 explicitly taught adding a boost converter to the supply of a similar linear amplifier to ensure stable operation and prevent distortion when the battery voltage depletes. Hanington was cited as disclosing a standard, well-known boost converter design (with an inductor, transistor, diode, and capacitor) that a person of ordinary skill in the art (POSITA) would have used to implement the teaching of Choi 2010.
    • Motivation to Combine: A POSITA would combine these references because they address the same field of power supply modulators for PAs. Petitioner argued that Choi 2010 expressly taught using a boost converter to solve the known problem of performance degradation due to battery depletion in systems like Chu's. This teaching provided a clear motivation to modify Chu’s architecture with the boost converter from Choi 2010, implemented using the conventional design shown in Hanington, to improve robustness.
    • Expectation of Success: The combination involved applying a known solution (a boost converter) to a known device (Chu's hybrid amplifier) to solve a known problem (battery depletion). Petitioner contended this would have yielded the predictable result of a more robust power supply that maintains performance over a wider range of battery voltages.

Ground 2: Obviousness of Claim 11 over Chu, Choi 2010, Hanington, and Myers

  • Prior Art Relied Upon: Chu (a 2008 IEEE journal article), Choi 2010 (a 2010 IEEE conference paper), Hanington (a 1999 IEEE journal article), and Myers (Patent 5,929,702).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds upon Ground 1 to address the additional limitations of dependent claim 11, which requires the capability to generate the second supply voltage based on either the boosted supply voltage or the first (battery) supply voltage. Petitioner asserted that the base combination of Chu, Choi 2010, and Hanington taught the apparatus of claim 10. The petition added Myers, which taught a method for efficiently amplifying an envelope signal by selecting between multiple power sources based on operating conditions, such as the input signal's amplitude. This selection improves efficiency by using a lower power source when sufficient and a higher one only when needed.
    • Motivation to Combine: A POSITA would be motivated to incorporate the power-selection functionality of Myers into the Chu/Choi/Hanington combination to further improve efficiency and preserve battery life—a primary goal in mobile device design. By selecting the lower battery voltage when the signal envelope is low and the higher boosted voltage only when the envelope is high or the battery is depleted, the system avoids the waste of supplying an unnecessarily high voltage. Petitioner argued this was a common-sense design choice for power management.
    • Expectation of Success: Implementing Myers’s selection capability into the proposed combination was argued to be a straightforward application of known design principles. A POSITA would have known to use a standard multiplexer circuit to perform the selection, yielding the predictable and expected benefits of improved power efficiency and extended battery life.

4. Key Claim Construction Positions

  • Petitioner argued that several terms in the challenged claims were means-plus-function limitations under 35 U.S.C. §112, ¶ 6. The constructions for these terms were central to the invalidity arguments.
  • "means for generating a boosted supply voltage..." (claim 10): Petitioner identified the claimed function as "generating a boosted supply voltage based on a first supply voltage." The corresponding structure disclosed in the ’558 patent was identified as boost converter 180, which includes an inductor, NMOS transistor, diode, and capacitor, as depicted in the patent’s Figure 6.
  • "means for generating a second supply voltage..." (claim 10): Petitioner identified the function as "generating a second supply voltage based on the envelope signal and the boosted supply voltage." The corresponding structure was identified as envelope amplifier 170a, comprising an operational amplifier (310), a driver (312), a PMOS transistor (314), and an NMOS transistor (316).

5. Relief Requested

  • Petitioner requests institution of inter partes review and cancellation of claims 10 and 11 of the ’558 patent as unpatentable under 35 U.S.C. §103.